ML18051A245
| ML18051A245 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/20/1982 |
| From: | Dewitt R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML18051A244 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.3, TASK-TM GL-82-12, NUDOCS 8212280089 | |
| Download: ML18051A245 (6) | |
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CONSUMERS POWER COMPANY
-DOCKET ""50~255 - -L-ICENSE DPR-20* ~ PALISADES PLANT -
REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS For the reasons hereinafter set forth, it is requested that the Technical Specifications contained in the Provisional Operating License DPR-20, Docket 50-255, issued to Consumers Power Company on October 16, 1972, for the Palisades Plant be changed as described in Section I below:
I.
CHANGE(s)
A. The title of "Plant Superintendent" should be changed to "Plant General Manager" in Section 6.1.1.
B. Add Section 6.1.2:
"The Shift Supervisor shall be responsible for the shift command function.
A directive to this effect shall be issued and signed by the Vice President - Nuclear Operatio~s."
- C. Revise item c of Section 6.2.2 to read as follows:
"At least two licensed Operators shall be present in the control room during approach to criticality through 15% power, scheduled
. reactor shutdown and during recovery from reactor trips.
D. Add an asterisk to the end of item d of Section 6.2.2.
Consquently, the footnote at the bottom of page 6-1 should be revised to read:
"* Radiation Protection coverage and Fire Brigade composition may be less th.an the minimum requirements for a period 'of time not to exceed two hours in order to accommo4ate unexpected absence provided immediate action is taken to restore the minimum requirements."
E. Revise item e of Section 6.2.2 to read.as follows:
"All core alterations, after the initial fuel loading, shall either be performed by a licensed Reactor Operator under the general supervision of a Senior Reactor Operator or a nonlicensed Operator directly supervised by a licensed Senior Reactor Operator (or Senior Operator Limited to Fuel Handling) who has no other concurrent responsibilities during this operation."
F. The second sentence of Section 6.2.2, item f, should read:
"The Fire Brigade shall not include 3 members II G. Add item g to Section 6.2.2.
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I.
CHANGE(s) (Continued)
I i
- 2 "The Shift Technical Advisor/Shift Engineer (STA/SE) shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design and/or operations, and response and analysis of the plant for transients and accidents."
I..Replace Figure 6.2-2 with revised Figure 6.2-2, "Plant Organization."
J. Replace Table 6.2-1 with revised Table 6.2-1, "Minimum Shift Crew Composition."
K. In Section 6.4.1, the title of "Nuclear Training Administrator" should be changed to "Director of Nuclear Operations Training."
L. Revise Section 6.4.2 to read as follows:
"The Director of Property Protection is responsible for the development, revision, approval and implementation of the Fire Brigade training program.
This training, shall, as practicable, meet or exceed the requirements of Section 27 of the NFPA Code-1975.
Fire Brigade traini~g drills shall be held at least quarterly."
M. Reformat all of Section 6.9.
N. Delete the Footnotes which follow Section 6.9.2 and are located on page 6-17 of the existing Palisades Technical Specifications.
O. Revise Section 6.10 to read as follows:
"In addition to the applicable record retention requirements of Title 10, Code of Federal Regulations, the following records shall be retained for at least the minimum period indicated:"
P. Move item e and item f from Section 6.10.1 to Section 6.10.2.
Q.
R.
The word "current" should be deleted from item e.
These two items shall be qualified in Section 6.10.2 with the footnote "Effective as of December 31, 1982."
Revise item g of Section 6.10.1 to read. as follows:
"Records of changes made to the procedures required by' Specification 6.8.1. "
Delete item k of Section 6.10.1.
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S. Revis~ item g tif Section 6.10.2 to read a~ follows~
"Records of Quality Assurance activities required by the QA Manual."
T. Revise item i of Section 6.10.2 to read as follows:
"Records of meetings of the PRC and NSB."
U. Change the asterisk at the end of the first sentence in Section 6.12.1 and the footnote, to a number 2.
NOTE:
Revised Technical Specifications pages are attached.
Proposed changes are shown by a vertical line in the right hand margin.
II.
DISCUSSION 3
The above proposed Technical Specifications changes are requested in order to clarify existing requirements, to achieve closer conformance to the Standard Technical Specifications and to bring th~ Palisades Technical Specifications into ~loser agreement with our Midland Plant and/or Big Rock Point Technical Specifications.
The following describes the proposed changes:
Items A, H and K These changes result from management title changes.
Item B Section 6.1.2 has been added to meet the intent of the Standard Technical Specifications.
Item C The existing wording ". *
- du.ring reactor startup. * * " is not appropriate since the Palisades Plant does not have a startup mode; hence, it is not defined.
Item D A footnote has been added to conform to the Standard Technical Specifications.
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II.
DISCUSSION (Continued)
Item E Section 6.2.2.e has been.revised for clarification purposes and is now identical to the Big Rock Point Technical Specifications.
Item F This change is editorial only.
Item G This section has been added to incorporate the revised working hour guidelines as prescribed by NRC Generic Letter No 82-12 dated June 15, 1982.
Item I The changes to Figure 6.2-2 represent the proposed plant management organization.
The most significant change involves the reportability of the newly established position of Chemistry and Health Physics Superintendent.
The Plant Health Physicist will report directly to the Chemistry and Health Physics Superintendent who in turn will report directly to the Operations and Maintenance Superintendent.
4 A Radiation Safety Manager (RPM as defined in Regulatory Guide 1.8) shall be designated by the Plant General Manager and shall be either the Chem/HP Superintendent, the Plant Health Physicist or a Radiation Safety Supervisor.
The Radiation Safety Manager shall have direct access to the Plant General Manager in the matters of radiation safety.
The Operations and Maintenance Superintendent has the responsibility for the day-to-day operation of the plant, whereas, the Plant General Manager's responsibilities and duties are administrative in nature.
Consumers Power Company submittal dated August 3, 1979 provided a comparison of Consumers Power Company organizational titles to those of ANSI Nl8.l-1971.
As noted, the Palisades Operations and Maintenance Superintendent meets or exceeds the minimum qualifications of ANSI Nl8.l-1971 for the Plant Manager.
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II.
DISCUSSION (Continued)
Item J Table 6. 2-1 has been expanded to in.elude all the individuals required to be on shift at the Palisades Plant.
This change is being requested in order that a single document may be referenced which contains the complete minimum shift crew composition.
Requirements for dealing with an absence of a on-duty shift crew member have also been added.
Item L This section has been revised to make it consistent with Consumers Power Company's Fire Plan in addition to the Standard Technical Specifications.
Item M Section 6.9 has been reformatted to make it consistent with the Standard Technical Specifications.
Consumers Power Company Technical Specifications submittal dated November 12, 1982 was formatted in an equivalent manner.
The new format for Section 6.9 involves the use of new subsection numbers instead of letters.
Although this section may appear differently, no content changes have been made.
Item N These footnotes are considered irrelevan*t and thus have been removed.
Items 0, P, Q, S Changes are requested in order to conform to the Standard Technical Specifications.
Item R The inclusion of the Chlorine Treatment Records in the Record Retention section of the Palisades Technical Specifications is considered inappropriate.
These records are addressed in the National Pollution Discharge Elimination System (NPDES) program.
Item T 5
As was proposed in Consumers Power Company's November 12, 1982 submittal, the Safety and Audit Review Board (SARB) is to be renamed the Nuclear Safety Board (NSB).
Item U This change is editorial only.
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- e III. CONCLUSION Based on the foregoing, both the Palisades Plant Review Committee and the Safety and Audit Board have reviewed these changes and find them acceptable.
CONSUMERS POWER COMPANY BY ~})JM}4/' ~1 R B DeWitt~ Vice President Nuclear Operations Sworn and subscribed to before me this 17th day of December 1982.
Dempski, Notary Jackson County, Michigan Mi commission-expires December 14, 1983.
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